Hush Hush in Wilmot (pt. 2)
Farmland, Employment Lands, and the Countryside Line
Last week, I provided an introduction to the potential expropriation of several farms in Wilmot Township (read part one of the series here). Today, we will take a closer look at the various local policies and plans that should be considered in these decisions. (It’s a long post this week, so you may need to click ‘Read entire message’ at the bottom of your email).
What about the Region’s Official Plan?
The Region’s Official Plan is an essential document that guides long-term growth and development in the Region to 2051. As described in this CBC article, “The official plan is used to decide where developers can build and how communities within the region can grow. It's an important document for protecting the countryside line, on how to increase transportation options and to protect drinking water and significant environmental areas.” Under the province's Planning Act, the Region has to review its official plan every five years. The latest review was only recently approved by the province (with modifications) on April 11, 2023.
Key elements of the Regional Official Plan are:
a fixed border between rural and urban areas;
directing growth to make better use of land and municipal services within the built up areas of the Region;
increasing transportation choice, including the creation of a rapid transit system;
protecting our drinking water and significant environmental areas; and
increasing the quality of life of citizens in Waterloo Region.
One of the concerns about creating a mega industrial site in Wilmot Township is that it doesn’t seem to be a part of this latest version of the Official Plan. Stewart Snyder, a dairy farmer on Nafziger Rd says of the recently approved plan “There was no mention in it of putting together a huge parcel of shovel-ready land for a large investment in Wilmot Township.” Mike Farwell agrees as he writes, “The official plan included enough employment lands to ensure our sustainable growth for the next 30 years. Curiously, the land now being assembled in Wilmot Township was not identified as necessary employment land.”
It’s possible that local elected officials risk losing the faith of residents when it seems they’re turning their backs on that plan now. As Kitchener resident Sue Savor wrote to regional officials recently, “The thousands of hours of input into Waterloo Region’s Official Plan, with the priority being environmental sustainability, were ignorantly and insultingly thrown out by this provincial government in favour of industry.”
What about the need for Employment Lands?
As our region grows, there is a need to dedicate space as ‘employment lands’. The province is encouraging municipalities to assemble ‘shovel-ready’ lands. Shovel-ready lands are generally considered to be lands with necessary approvals, servicing and transportation infrastructure in place, as well as an owner willing to develop or sell.
A recent joint statement from the Region of Waterloo and the Township of Wilmot confirms that they are working with higher levels of government to assemble shovel-ready land for a large investment. Kitchener-Conestoga MPP Mike Harris released a statement: “The Region of Waterloo and Wilmot Township are collaborating to prepare land for development, aiming to establish shovel-ready sites to attract economic investments and generate employment opportunities. The process of assembling land is ongoing to create these shovel-ready sites, facilitating significant economic investments and bolstering the vitality of Waterloo Region as it progresses towards accommodating one million residents by 2050.”
The Business and Economic Support Team of Waterloo Region (BEST WR) penned an open letter earlier this month in support of developing shovel-ready land. BEST WR is comprised of the Waterloo Region Economic Development Corporation, Cambridge Chamber of Commerce, Explore Waterloo Region, Greater KW Chamber of Commerce, and Communitech.
They noted that as the Region continues to grow, “employment lands are essential to attracting anchor investment and job creation opportunities for our region.” They believe that “shovel-ready land is critical and will be pivotal to the ongoing success of our future economy and communities across Waterloo Region.”
The letter outlines the types of land that are desired in “global site selection” as a “contiguous large parcel that is flat, close to a major power supply, is not in an environmentally protected area and situated within a 45-minute radius of a large, skilled and talented workforce.”
The Chief Executive of the Greater Kitchener-Waterloo Chamber of Commerce, Ian McLean says “the J.M. Schneider factory left Kitchener more than nine years ago because there was no other suitable site for the large plant, and future investments will also be lost without a big parcel of shovel-ready land.” McLean claims, “If we put this (mega-site) together, there will be no shortage of companies willing to make a billion-dollar investment.”
While McLean and the BEST WR team believe, “we cannot as a community continue to reject opportunities for stable, secure and well-paying jobs,” it seems they are forgetting that these are not simply vacant lands, but productive farm lands which provide both jobs and food. Yet, McLean called “the land-assembly opposition a knee-jerk reaction by NIMBYs who don’t get it.” As the co-founder of Waterloo Region Yes In My Backyard, an organization that advocates for communities to build up and not out - for this exact reason - it’s not often that I am accused of being a NIMBY. For me, this isn’t about being anti-growth, but rather understanding (and respecting) the vital role that farmers and our prime agricultural land play in feeding our growing cities.
What about the East Side Lands Employment Area?
While the Region seemingly did not have their eyes on these Wilmot Lands while creating the recent Official Plan Review, that doesn’t mean Employment Lands were not on the radar at all. The Region has been busy over the last several years creating the East Side Lands Employment Area. This area includes thousands of acres bounded roughly by the Region of Waterloo International Airport to the north and Highway 401 to the south, Riverbank Drive to the west and Speedsville Road to the east. Reference to these lands are found even back in the 2015 Official Plan.
As Luisa D’Amato notes, “Lands within this employment area are intended to accommodate new large-lot manufacturing or business park uses serviced by a municipal water and wastewater system in close proximity to major good movement facilities and corridors, including the Region of Waterloo International Airport.” That seems to check off many of the boxes for ‘global site selection’ listed earlier.
Worth noting, is that “unlike the area of prime agricultural land in Wilmot that the Region of Waterloo is threatening to expropriate from farmers, these East Side lands were openly discussed when the region was making its plans about how growth was going to happen.” Rod Regier, the Region’s Commissioner of Planning said in 2021, “As those (East Side) lands open up, the region is ensuring early planning includes not just sewers, roads and water services, but also easy, convenient transit connections. The area could eventually employ tens of thousands of people, and it makes sense to design it so that all those workers don’t have to travel there by car.”
The Region clearly has a desire to develop shovel-ready employment lands with the East Side Lands, and the recent Official Plan makes no mention of developing a similar plan in Wilmot - so, it’s unclear why the Wilmot Lands are being pursued. Especially, as Luisa D'Amato raises, “when servicing the Wilmot land parcel will be difficult, slow and expensive, because there is no more wastewater capacity in Wilmot beyond the developments that have already been approved.”
What about the need to protect our farmland?
Jenn Pfenning is a local farmer and the president of the National Farmers Union. She asks “Why are we giving up prime agricultural land when we don’t have enough of it?”
Every day Ontario loses about 300 acres of farmland. In this Twitter thread, Pfenning digs into the details of why these lands and their ‘Class 1’ soil are so important to our region and province.
Some of those supporting the expropriation of the Wilmot Lands view these lands as ripe for development, seeming to forget that these are extremely productive lands already, providing jobs and food to our cities and towns. Ontario’s premier declared, "A lot of smaller towns like Wilmot, they need money. So what better way than clear some land and create some development. I'm all for it." These lands that should ‘just be cleared’ provide many economic benefits:
Ontario's agri-food industry contributes $48.8 billion in Gross Domestic Product (GDP) to the provincial economy (6.4% of total Ontario GDP).
Ontario accounts for $14.5 billion, or 41.9% of Canada's national food and beverage GDP, and also represents the third largest contributor of farm cash receipts in the country in 2021.
More than 750,000 Ontarians, or 1-in-10 of the province’s labour force, are employed throughout the agri-food supply chain.
Each job in the primary agriculture sector has been shown to support an additional four jobs in the wider regional economy.
The Ministry of Agriculture page notes: Ontario's agri-food sector is, and always will be, a cornerstone of our thriving economy. It is an important economic driver for the province and Canada, and a significant jurisdiction internationally.
The Ontario Federation of Agriculture is interested in working with the government to find alternative locations for a proposed mega-site. Its president, Drew Spoelstra, states, “We understand the urgency of the situation in Wilmot Township and remain concerned about the accelerating loss of farmland in Ontario. OFA strongly supports rural economic development where it does not undermine our precious and finite agricultural resources.”
What about the Countryside Line?
According to Hold The Line, “The Region of Waterloo’s Countryside Line is a boundary that protects the cultural, economic, and environmental heritage of our rural lands from the pressures of urban sprawl. It protects the distinctiveness of rural communities at a time when other cities in Ontario are annexing rural areas for suburban expansion.”
The Region of Waterloo’s 2015 Official Plan declared, “The countryside is made up of many unique natural and cultural heritage features as well as valuable natural resources, including agricultural lands, woodlands, mineral aggregate deposits and groundwater recharge areas. These assets form part of the region’s rich natural capital and contribute to the community’s quality of life.”
Hold The Line outlines several important reasons to protect the Countryside Line, including: ensuring safe drinking water; encouraging compact, lively urban neighbourhoods; and, financial responsibility. The possible expropriation of the Wilmot Lands is just one example of how the Countryside Line is under threat. In an open letter from Hold The Line, they write, “By aiding a major land expropriation outside the Countryside Line, the Region of Waterloo has abandoned its values of smart growth, and of maintaining a balance of urban and rural areas in the Region.”
Columnist Mike Farwell reminds readers that “these 700-plus acres in Wilmot (outlined above in pink) have always been protected by the Countryside Line. They were never planned for development, and nobody asked them to be. Until now.” The Region’s own documents outline the importance and supposed permanence of these protected areas: “The Protected Countryside will permanently protect these critical areas from urban development to ensure the region’s continued environmental and economic health.”
Last year, the Housing Minister’s Office reiterated the importance of maintaining the Countryside Line, declaring "it is important to note that the existing countryside line will be maintained and this balanced approach will allow for growth while protecting the environment for future generations."
MPP Catherine Fife has expressed concerns about expropriating Wilmot farm land, saying “the government is overriding and rewriting local official plans to move urban boundaries and violate the countryside line by opening up previously protected land to development.”
What is Wilmot Council’s role in this?
I’m still reading through some of the Wilmot Council agendas and reports (my spouse was quite thrilled when I informed him that in addition to the many local council meetings I already follow, I have now apparently added Wilmot to that list!). Here’s what I understand so far…
While it seems that the Region of Waterloo and the Province are pushing for the expropriation of the Wilmot Lands, it’s also clear that Wilmot Council and/or staff are advocating for growth and expansion of employment lands in the township.
According to this Wilmot Council staff report, in conversation with the province through Minister Paul Calandra, “proposed amendments to the Official Plan Adjustments Act, 2023 follow consultation with affected municipalities, and, if passed, would update official plans in response to municipal feedback.” (p.152) This essentially allows Wilmot to override the Region’s Official Plan.
Wilmot Council provided comments that stated their appreciation for “the opportunity for the Township to present its longstanding vision for the community directly to the Province.” In the November 2023 Wilmot Council meeting, regarding this provincial feedback opportunity, staff state, “the vision for Wilmot has been consistently presented to the Region for 20 years but has not successfully been reflected in Regional plans.” (14:25 mark)
Wilmot staff recommend that the lands pictured below in beige should be designated as employment lands. They note that the recently approved Regional Official Plan provided limited additional Employment Areas within Wilmot. Staff comment, “These lands were not included in the Minister’s original approval, or the most recent modification, but do form part of the Township’s longstanding vision for the area.” It’s worth noting that the Wilmot Lands facing expropriation neighbour these lands to the south. Also, the Countryside Line outlined below is not reflective of the original Countryside Line but where staff believe the line should be, after breaching the Countryside Line in 2023 (see map above - area outlined in red). In response to that first breach, Chair Redman said, “They moved some of the lines. I don’t think it’s huge.”
The Wilmot Council staff report concludes: “The inclusion of these employment lands serves to facilitate a balanced approach to community growth, remains consistent with the Township’s vision to achieve concentrated growth between Baden and New Hamburg, and ultimately assists with filling a void in readily available employment lands within the greater Waterloo region.” (p.156) Between the East Side Lands, Waterloo West Side Lands, and existing (but as I understand, still vacant) employment lands in Wilmot, I’m not certain there is a ‘void of readily available employments lands’ in our region. Even if there is, I’m not convinced that destroying quality farm land is the way to fill such a void.
While I suspect many of us believed the lands outside of the Countryside Line would be some of the most secure and protected lands in the province, it doesn’t appear to be the case.
A note before you go: One of my goals with Citified is to provide additional context to the often nuanced issues facing local councils. I rely on comments from elected officials, in addition to staff reports, council meetings, and local news articles to better understand these issues. Due to the silence from local councils and elected officials on this issue, it has been difficult to provide the larger context that I seek to offer in this newsletter. I am working with what I have access to, but I’m certain those who are silent on this issue currently, would add a perspective that perhaps is not represented in these posts. As additional details come to light, I will do my best to share those here.
In the next post in this series, we’ll look at what staff and elected officials are saying (or not) about the Wilmot Lands and what actions concerned residents are taking. We’ll also take a deeper look at some of the provincial policies and recent legislation that may impact the Wilmot Lands. Thanks for reading! If you found this post informative, please share.
Once again Melissa thank you for bringing the information to the public. Thanks for gently reminding those in charge that when it comes to decisions like this, keeping people in the dark will not win support or understanding. It is very troubling that work already done regarding employment lands by the region itself that seem to have been tossed aside along with the countryside line to acquire these 700 acres of working, productive farmland. Thank you for calling out the misguided comments of Ian McLean at the KW Greater Chamber of Commerce and Ontario's Premier.
This whole business stinks and it would be encouraging to see our elected officials, and champions of progress start speaking about it without deflection and some integrity. Acknowledging that a NDA is in play, would it not be beneficial to bring us, the communities they say will be benefitting from the expropriation of active farms, on board and to an informed position.
Thank you, again, for providing so much information about what is happening. Agreed that there is way too much silence around this issue from many in governing & decision-making positions. I’ll look forward to your next piece on this very important issue!